Bruce and Lois Zenkel, et al. - Page 24

                                       - 24 -                                         
               4.  Ira and Helen Selvin                                               
               Petitioners Ira and Helen Selvin (the Selvins) resided in              
          Roslyn Estates, New York, when their petition was filed.  Ira               
          Selvin (Selvin) received a B.S. degree from New York University             
          School of Commerce.  Excluding his active service in the U.S.               
          Army during World Wars I and II, Selvin has practiced accounting            
          for his entire career until he retired in approximately 1980.  He           
          was a sole practitioner for 30-35 years and serviced many clients           
          in the garment industry.  Selvin eventually turned his practice             
          over to the accounting firm of Cooper, Selvin & Strasburg.                  
          Although it maintained an office for him, Selvin never actively             
          worked for that firm.  On their joint 1981 Federal income tax               
          return, the Selvins reported gross income from interest,                    
          dividends, capital gains, pensions or annuities, and other                  
          sources in excess of $172,000.                                              
               In 1981 Selvin acquired an interest in Scarborough as a                
          nominee on behalf of himself and other members of his accounting            
          firm (hereinafter "the Selvin group").  The Selvin group invested           
          $180,000 for an 18.27-percent interest in Scarborough.  The                 
          amount of Selvin's share in Scarborough is not entirely clear               
          from the record in docket No. 10147-91.  Selvin stated that he              
          invested $30,000 in Scarborough, which is the equivalent of a               
          3.05-percent interest (30,000/180,000 = 16.67 percent; .1667 x              
          .1827 = 3.05 percent).  However, the Selvins claimed $44,626 of             






Page:  Previous  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  Next

Last modified: May 25, 2011